APPENDIX
H
MODELED
ATTAINMENT
TEST
SAN
ANTONIO
EAC
REGION
ATTAINMENT
DEMONSTRATION
MARCH
2004
H­
2
Appendix
H
Table
of
Contents
Page
Modeled
Attainment
Test
Methodology
                  .
H­
3
Current
Period
                          
H­
3
Current
Site­
Specific
Design
Values
                .
H­
3
Relative
Reduction
Factor
                     
H­
4
Future
Site­
Specific
Design
Values                 ..
H­
5
Modeled
Attainment
Test
Results
after
Inclusion
of
Local
Clean
Air
Strategy
Implementation
                         ...
H­
5
List
of
Tables
Page
Table
H­
1
Design
Values
at
Monitors
during
Three­
year
Period
Straddling
the
Most
Recent
EI
(
1999)
                 ..
H­
3
Table
H­
2
Design
Values
at
Monitors
during
Three­
year
Period
Anticipated
for
Nonattainment
Designation
(
2001
 
2003)
         .
H­
4
Table
H­
3
Predicted
Current
and
Future
8­
hour
Daily
Maxima
       
H­
4
Table
H­
4
Relative
Reduction
Factor
by
Monitor             
H­
4
Table
H­
5
Attainment
Test
Results
at
SAER
Monitors
          ..
H­
5
Table
H­
6
Modeled
Attainment
Test
Results
that
Account
for
Implementation
of
Stage
I
Vapor
Recovery
                 ..
H­
6
H­
3
MODELED
ATTAINMENT
TEST
METHODOLOGY
The
modeled
attainment
test
for
the
SAER
was
conducted
by
completing
a
series
of
steps
that
are
described
in
EPA's
Draft
Guidance
on
the
Use
of
Models
and
Other
Analyses
in
Attainment
Demonstrations
for
the
8­
hour
Ozone
NAAQS.
These
steps
require
identifying
the
"
current
period"
to
use
in
the
attainment
test,
calculating
the
current
site­
specific
design
value,
calculating
the
relative
reduction
factor,
and
calculating
the
future
site­
specific
design
values.
The
2007
modeled
data
listed
in
the
following
tables
are
the
predicted
averages
from
the
base
case.
Therefore,
these
results
represent
a
preliminary
attainment
test
conducted
prior
to
modeling
local
clean
air
strategies.

Current
Period
To
determine
the
current
period
to
use
in
an
attainment
test,
EPA
guidance
suggests
reviewing
monitored
data
for
the
three­
year
period
straddling
the
year
represented
by
the
most
recently
available
emissions
inventory
and
the
three­
year
period
that
is
anticipated
to
be
used
to
designate
the
area
nonattainment.
For
the
SAER,
the
most
recently
available
emissions
inventory
is
for
the
year
1999.
Therefore,
ozone
measurements
for
the
three­
year
period
between
1998
 
2000
represented
one
data
set
used
in
the
analysis.
The
three­
year
period
anticipated
for
nonattainment
designations
is
2001
 
2003.
The
current
monitored
design
values
are
selected
based
on
the
higher
of
the
two
estimates
at
each
monitor.

Current
Site­
Specific
Design
Values
The
current
site­
specific
design
value
was
calculated
at
each
monitor
by
identifying
the
fourth
highest
concentration
in
each
of
three
consecutive
years
and
determining
the
mean
(
average)
of
the
three
year's
data.
The
design
values
were
computed
for
both
three
year
periods,
1998­
2000
and
2001­
2003.
Table
H­
1
provides
the
current
design
value
by
monitor
for
the
1998­
2000
period.
Likewise,
table
H­
2
lists
design
values
for
the
years
2001­
2003.
The
highest
design
values,
by
monitor,
when
comparing
the
two
tables
are
highlighted
in
yellow.

Table
H­
1.
Design
Values
at
Monitors
during
Three­
year
Period
Straddling
the
Most
Recent
EI
(
1999).

Monitoring
Site
4th
High
8­
hr
Daily
Max.
1998
4th
High
8­
hr
Daily
Max.
1999
4th
High
8­
hr
Daily
Max.
2000
Average
4th
High
8­
hr
Daily
Max.
CAMS
23
*
89
ppb
91
ppb
77
ppb
85.67
=
85
ppb
CAMS
58
**
87
ppb
87
ppb
80
ppb
84.67
=
84
ppb
CAMS
59
***
76
ppb
81
ppb
82
ppb
79.67
=
79
ppb
CAMS
678
****
84
ppb
70
ppb
77
ppb
*
At
San
Antonio
Northwest
CAMS
23
(
Marshall
High
School),
the
1998
fourth­
highest
reading
was
89
ppb
(
excusing
May
7,
1998
as
a
smoke
day,
which
had
a
value
of
93
ppb).
**
Camp
Bullis
CAMS
58
went
online
August
12,
1998
***
Calaveras
Lake
CAMS
59
went
online
May
14,
1998
****
CPS/
Trinity
Pecan
Valley
CAMS
678
went
online
March
11,
1999
H­
4
Table
H­
2.
Design
Values
at
Monitors
during
Three­
year
Period
Anticipated
for
Nonattainment
Designation
(
2001
 
2003).

Monitoring
Site
4th
High
8­
hr
Daily
Max.
2001
4th
High
8­
hr
Daily
Max.
2002
4th
High
8­
hr
Daily
Max.
2003
Average
4th
High
8­
hr
Daily
Max.
CAMS
23
78
ppb
104
ppb
86
ppb
89.33
=
89
ppb
CAMS
58
81
ppb
95
ppb
85
ppb
87
ppb
CAMS
59
78
ppb
81
ppb
76
ppb
78.33
=
78
ppb
CAMS
678
72
ppb
80
ppb
76
ppb
76
ppb
76
ppb
Relative
Reduction
Factor
The
modeled
attainment
test
also
requires
the
calculation
of
a
relative
reduction
factor
(
RRF).
The
RRF
is
the
ratio
of
the
future
8­
hour
daily
maximum
concentration
predicted
near
a
monitor
to
the
current
8­
hour
daily
maximum
concentration
predicted
near
a
monitor.
Since
the
photochemical
model
uses
a
4­
km
grid
system,
the
area
near
a
monitor
was
defined
as
the
7x7
array
of
grid
cells
surrounding
the
monitor.
The
predicted
future
and
current
8­
hour
daily
maximum
concentrations
are
listed
in
table
H­
3.

Table
H­
3.
Predicted
Current
and
Future
8­
hour
Daily
Maxima.

Monitoring
Site
Predicted
8­
hour
daily
maximum
ozone
(
ppb)
­
1999
Predicted
8­
hour
daily
maximum
ozone
(
ppb)
­
2007
CAMS
23
88
ppb
84
ppb
CAMS
58
87
ppb
82
ppb
CAMS
59
78
ppb
73
ppb
CAMS
678
80
ppb
77
ppb
Using
the
results
of
the
most
recent
model,
Run
18
Base
Case
B,
the
relative
reduction
factors
were
calculated
for
each
monitor
using
the
formula
shown
below.
Table
H­
4
lists
the
RRF
for
each
SAER
monitor.

Future
8­
hour
daily
maximum
concentration
near
site
I_
=
Relative
Reduction
Factor
Current
8­
hour
daily
maximum
concentration
near
site
I
Table
H­
4.
Relative
Reduction
Factor
by
Monitor.
Monitoring
Site
Relative
Reduction
Factor
CAMS
23
.95
CAMS
58
.94
CAMS
59
.94
CAMS
678
.97
H­
5
Future
Site­
Specific
Design
Values
The
future
site­
specific
design
values
were
calculated
using
the
formula:

(
DVF)
I
=
(
RRF)
I(
DVC)
I
where
(
DVC)
I
=
the
current
design
value
at
monitoring
site
I
(
RRF)
I
=
the
relative
reduction
calculated
near
site
I
(
DVF)
I
=
the
estimated
future
design
value
for
the
time
attainment
is
required
Table
H­
5
lists
the
results
of
calculating
a
future
design
value
for
each
monitoring
site.
The
attainment
test
is
passed
when
the
future
design
value
at
each
monitor
is
 
84
ppb.
As
shown,
the
attainment
test
was
passed
for
all
SAER
monitors.

Table
H­
5.
Attainment
Test
Results
at
SAER
Monitors.

Monitor
Modeled
Average
Daily
Maximum
Ozone
Concentration
­
1999
Modeled
Average
Daily
Maximum
Ozone
Concentration
­
2007
RRF
Current
Design
Value
Future
Design
Value
Pass
/
Fail
Status
CAMS
23
88
ppb
84
ppb
0.95
89
ppb
84
ppb
Pass
CAMS
58
87
ppb
82
ppb
0.94
87
ppb
82
ppb
Pass
CAMS
59
78
ppb
73
ppb
0.94
79
ppb
74
ppb
Pass
CAMS
678
80
ppb
77
ppb
0.97
77
ppb
74
ppb
Pass
MODELED
ATTAINMENT
TEST
RESULTS
AFTER
INCLUSION
OF
LOCAL
CLEAN
AIR
STRATEGY
IMPLEMENTATION
The
future
design
value
results
listed
in
table
H­
5
show
that
the
2007
future
case
model
attains
the
8­
hour
ozone
NAAQS
without
resort
to
local
control
strategy
implementation.
However,
the
local
SAER
air
quality
planners,
elected
officials,
and
citizens
have
chosen
to
implement
local
control
strategies
to
assure
this
attainment
result.

As
described
in
appendix
K,
three
strategies
have
been
chosen.
The
single
locallyimplemented
clean
air
strategy,
Stage
I
vapor
recovery,
is
creditable,
enforceable,
and
permanent
in
the
terms
required
for
credit
taken
in
the
SIP.


Stage
I
vapor
recovery
for
service
stations
of
25,000
gallons
throughput
of
gasoline
or
more
per
month
will
be
implemented
and
operational
no
later
than
December
31,
2005.

The
attainment
test
was
recalculated
based
on
results
of
modeling
Stage
I
vapor
recovery
in
the
4­
county
SAER.
Table
H­
6
provides
the
future
design
values
when
the
impact
of
the
vapor
recovery
strategy
is
taken
into
account.
Although
EPA
guidance
allows
for
truncation
of
decimals
when
calculating
future
design
values,
these
results
are
listed
to
two
decimal
places
so
that
the
effect
of
implementing
Stage
I
is
more
readily
apparent.
1
1
Of
11
clean
air
strategies
modeled,
including
ASM
with
OBD
II,
each
resulted
in
less
than
0.5
ppb
reduction
in
local
ozone
concentrations.
H­
6
As
demonstrated
by
this
table,
the
implementation
of
Stage
I
vapor
recovery
as
a
local
clean
air
strategy
is
projected
to
decrease
ozone
concentrations
at
all
SAER
monitors.
Therefore,
implementation
of
this
strategy
will
provide
an
additional
margin
of
safety
to
ensure
the
SAER
attains
the
8­
hour
NAAQS
by
2007.

Table
H­
6.
Modeled
Attainment
Test
Results
that
Account
for
Implementation
of
Stage
I
Vapor
Recovery.

Monitor
Future
Design
Value
(
ppb)
RRF
Future
Design
Value
with
Stage
I
(
ppb)
Pass/
Fail
Status
CAMS
23
84.52
0.949
84.40
Pass
CAMS
58
82.12
0.944
82.03
Pass
CAMS
59
74.48
0.943
74.44
Pass
CAMS
678
74.46
0.967
74.39
Pass
In
addition,
should
lower
Reid
Vapor
Pressure
to
7.2
pounds
per
square
inch
be
available
during
the
coming
ozone
seasons
through
negotiations
which
are
ongoing
at
the
time
of
this
document
submission
(
late
March
2004),
SIP
credit
will
be
taken
for
this
program
also.
See
Appendix
K,
Analysis
of
Additional
Evidence,
for
this
discussion.

It
is
important
to
note
that
Transportation
Emission
Reduction
Measures
(
TERMs)
can
be
quantified
as
SIP
creditable
reductions
as
well.
While
the
quantity
of
reductions
available
for
existing,
ongoing,
and
programmed
TERMs
have
not
been
calculated
and
included
in
the
attainment
demonstration
of
San
Antonio's
proposed
revisions
to
the
State
Implementation
Plan,
local
air
quality
planners
are
now
researching
measures
to
make
the
TERMs
enforceable.
The
region
is
intent
on
making
them
enforceable
and
calculating
SIP
credit
for
them
in
coordination
with
the
state
and
the
local
San
Antonio
/
Bexar
County
Metropolitan
Planning
Organization.
Even
if
SIP
credit
is
not
taken
here
for
the
secured
TERMs
projects
in
the
region,
the
benefits
of
the
reductions
accrue
as
Additional
Evidence
that
the
San
Antonio
region
will
reach
attainment.
See
Appendix
K,
Analysis
of
Additional
Evidence,
for
this
discussion.

Adopted
in
December
2002,
state
Senate
Bill
5
and
Senate
Bill
7
include
requirements
for
implementing
Energy
Efficiency
/
Renewable
Energy
Projects
and
for
calculating
resultant
reductions
in
ozone
precursor
emissions
through
energy
savings.
These
requirements
are
ongoing
in
Texas
and
highly
effective
in
the
San
Antonio
region.
Although
credit
is
not
taken
here
for
the
Energy
Efficiency
/
Renewable
Energy
Projects
in
the
region,
the
benefits
of
the
reductions
accrue
as
Additional
Evidence
that
the
San
Antonio
region
will
reach
attainment.
With
the
completion
of
the
work
accomplished
through
a
partnership
described
in
Appendix
K,
Analysis
of
Additional
Evidence,
the
San
Antonio
regional
air
quality
planners
will
include
the
SIP
credit
available.
